Pangasinan State University v. Lagoy
REITERATIONFacts
The Antecedents: Respondent Myrna T. Lagoy, a professor at Pangasinan State University (PSU), faced numerous oral and written complaints from 1994 to 1997 regarding falsification of time records, tardiness, dishonesty, insubordination, failure to submit grades, and other violations of Civil Service Law and PSU rules. Dean Clarita Jimenez formed a Fact-Finding Committee which found probable cause, recommending dismissal. A verified complaint was filed by Dean Jimenez with the PSU President, charging Lagoy with insubordination, gross neglect of duty, misrepresentation, habitual tardiness, usurpation of authority, and grave abuse of authority. A University Level Investigating Committee was formed, and after a preliminary investigation, the parties agreed to limit the charges to six: insubordination, gross neglect of duty, misconduct, dishonesty, habitual tardiness, and conduct prejudicial to the best interest of the service. Lagoy submitted her answer, and Dean Jimenez filed a reply. During this period, Lagoy filed an administrative complaint against Dean Jimenez, which was dismissed by the Civil Service Commission (CSC) for lack of merit. Procedural History: The PSU Investigating Committee found Lagoy guilty of the six charges and recommended forced resignation without benefits. The PSU Board of Regents, in Resolution No. 55, Series of 1998, found Lagoy guilty and imposed the penalty of forced resignation. Lagoy's motion for reconsideration was denied. Instead of appealing to the CSC, Lagoy filed a petition for certiorari with the Regional Trial Court (RTC), which dismissed her petition. Her motion for reconsideration was also denied. Her Notice of Appeal to the RTC was not given due course for failure to pay docket fees, and the RTC Order became final and executory. The PSU Board of Regents affirmed its previous resolution and authorized the PSU President to implement it. Lagoy was informed she was considered resigned and her name was deleted from the payroll. Lagoy's subsequent motions with the RTC and the Board of Regents were denied. The Office of the Solicitor General (OSG) opined that the case was already final and executory. Lagoy then filed an appeal with the CSC, which remanded the case to PSU for reinvestigation, citing the lack of a formal charge. The CSC denied the OSG's motion for reconsideration. The OSG filed a petition for review with the Court of Appeals (CA), which denied it for being filed late and for a defective certification of non-forum shopping. The CA denied the OSG's motion for reconsideration. The Petition: PSU filed a petition for review on certiorari with the Supreme Court, assailing the CA Resolutions that affirmed the CSC's order for reinvestigation. PSU argued that the CA erred in affirming the CSC's requirement for reinvestigation and that Lagoy's appeal to the CSC was filed out of time.
Issue(s)
Whether the Court of Appeals erred in affirming the Civil Service Commission Resolutions requiring Pangasinan State University (PSU) to conduct a reinvestigation. Whether the appeal filed by respondent Myrna T. Lagoy with the Civil Service Commission (CSC) should have been acted upon, considering it was filed out of time.
Ruling
The Supreme Court granted the petition, reversed the Court of Appeals' Resolutions, nullified the CSC Resolution requiring reinvestigation, and sustained the PSU Board of Regents' Resolution imposing forced resignation without benefits upon respondent Lagoy.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in affirming the Civil Service Commission Resolutions requiring PSU to conduct a reinvestigation: The Supreme Court held that the Court of Appeals erred. The Court emphasized the doctrine of exhaustion of administrative remedies, stating that parties must first resort to appropriate administrative authorities before elevating a controversy to the courts. PSU is a state-owned educational institution, and Lagoy is its employee, placing them under the jurisdiction of the CSC. The applicable Civil Service Rules required that after a prima facie case was found, the respondent be notified in writing of the charges and given an opportunity to submit an answer. The records showed that PSU complied with these provisions, affording Lagoy due process. Lagoy participated in the proceedings, submitted her answer, and attended hearings. After the Board of Regents issued Resolution No. 55, Series of 1998, finding her guilty and imposing forced resignation, Lagoy's proper recourse was to appeal to the CSC. However, she instead filed a petition for certiorari with the RTC, bypassing the administrative appeal process. This failure to exhaust administrative remedies was a fatal procedural flaw. On the issue of whether the appeal filed by respondent Lagoy with the CSC should have been acted upon, considering it was filed out of time: The Supreme Court ruled that the CSC should have dismissed Lagoy's appeal outright. The Court reiterated that the perfection of an appeal within the period prescribed by law is mandatory and jurisdictional. Lagoy received the PSU President's letter denying her motion for reconsideration on February 25, 1999. Under CSC rules, she had fifteen (15) days, or until March 12, 1999, to file her appeal with the CSC. Instead, she filed a petition for certiorari with the RTC on March 8, 1999. When she finally filed an appeal with the CSC on March 27, 2001, 348 days had passed since she received the denial of her motion for reconsideration. This significant delay meant that the Resolution No. 55, Series of 1998, of the PSU Board of Regents had long become final and executory. Therefore, the CSC had no jurisdiction to entertain her belated appeal, and the CA erred in affirming the CSC's decision to remand the case for reinvestigation.
Main Doctrine
The failure to appeal an administrative decision within the reglementary period renders the decision final and executory, barring subsequent appeals or re-litigation of the same issues. Resort to the courts via certiorari without exhausting administrative remedies is improper.